Can QRP (qualified replacement plan) transfer be rolled back into a new defined benefit plan?

Hi

Here is a new one for me.

Fiscal DB Plan - 7/31 year end. Overfunded 500k. This is a husband and wife plan only. They got paid out max 415 limits (compensation not dollar)

Plan terminated 7/31/2020. Benefits rolled into respective IRAs March 2021 and the excess was transferred to the QRP (profit sharing plan) by 7/31/2021 with a small remaining residue in October of 2021.

The DB account is still open with $0 balance.

The idea was to eat up the excess within 7 years as much as possible.

They now have opportunity for large salaries for 2021/2022 and wanted to see if a new DB plan can be set up and the excess can be transferred back into the new DB for satisfying the contributions?

Can this be done? If yes, I will have follow up questions.

Thank you

The initial "transaction" (DB plan termination, distribution and transfer of excess to QRP) has been completed, I don't see any legal basis for transferring from DC into a new DB, unless a termination of the DC might allow for a second generation QRP - a QRRP? However, the rules say if DC is terminated before the DB excess has been allocated (see the last sentence of this link) then the residual is a reversion, so I don't see as possible.

https://www.law.cornell.edu/definitions/uscode.php?width=840&height=800&iframe=true&def_id=26-USC-276939643-615333267&term_occur=999&term_src=title:26:subtitle:D:chapter:43:section:4980

Sounds as though they don't want new deductions for the large salaries?  Why not keep the DC as is and actually fund a new DB plan, perhaps...

No new deductions, they want to eat up the excess. New benefits based on new salaries (after adjusting for prior distributions) would be able to eat up the remaining excess.

I am no expert on spin-offs, would that work here?

I think a spinoff would have to preserve the DB or DC nature of the original.